Michael J. Murray defends the traditional doctrine of hell by arguing directly against its chief competitor, universalism. Universalism, says Murray, comes in “naïve” and “sophisticated” forms. Murray poses two arguments against naïve universalism before focusing on sophisticated universalism, which is his real target. He proceeds in this fashion because he thinks that his arguments against sophisticated universalism are more easily motivated against naïve universalism, and once their force is clearly seen in the naïve case they will be more clearly seen in the sophisticated. In this essay, I argue that Murray’s arguments against naïve universalism have no force whatsoever.